On a sale of a residential care facility, the taxpayer allocated substantially all of the sale price to operating agreements with the Quebec Ministry, and took the position that the election under s. 14(1.01) was available. After finding that the operating agreements constituted goodwill, the Directorate further stated:
With respect to the requirement [in s. 14(1.01)] that the cost of the eligible capital property “can be determined”, we are of the view that a zero cost would be acceptable. Indeed, the jurisprudence confirms that the cost of a capital property to a taxpayer can be nil. In this case, the taxpayer "acquired" the … operating agreements for such a cost.